CDM 2015 explained for contractors

The Construction (Design and Management) Regulations 2015 (CDM 2015) are the main set of regulations governing health and safety on UK construction projects. They apply to virtually every construction project, not just large commercial ones. If you are a contractor working in the UK, CDM 2015 affects you.

What CDM 2015 does

CDM 2015 defines who is responsible for health and safety at each stage of a project. It assigns specific duties to named parties depending on the size and nature of the project. The goal is straightforward: make sure health and safety is planned, managed, and coordinated from concept through to completion, not treated as an afterthought.

The regulations replaced CDM 2007 and simplified the duty holder structure. The old "CDM coordinator" role was removed, and the principal designer role was introduced.

The duty holders

CDM 2015 names six duty holders, each with specific responsibilities:

Client

The person or organisation commissioning the work. The client must make sure the project is properly managed, that duty holders are appointed, and that sufficient time and resources are allocated for health and safety. On domestic projects (work on someone's own home), the client's duties are automatically transferred to the contractor or principal contractor.

Principal Designer

On projects with more than one contractor, a principal designer must be appointed. They manage health and safety during the design stage, produce the pre-construction information pack, and coordinate design decisions so they do not create unnecessary risks during the construction phase. This role is separate from the architectural design role.

Principal Contractor

On projects with more than one contractor, a principal contractor must be appointed. They are responsible for managing health and safety during the construction phase. This includes producing the Construction Phase Plan (CPP), managing site access, coordinating subcontractors, running site inductions, and ensuring CDM compliance across the whole project. This is the duty holder role that most contractors reading this will hold.

Designer

Anyone who designs any element of the work. Designers must consider health and safety risks created by their designs and provide information about those risks to others who need it. This includes architects, structural engineers, and anyone specifying materials or methods.

Contractor

Any company or individual carrying out construction work. Contractors must cooperate with the principal contractor, follow the CPP, and ensure their own workers are competent and properly supervised.

Worker

Anyone who carries out the physical construction work. Workers must cooperate with others, report unsafe conditions, and follow site rules.

Notifiable projects

Some projects must be notified to the HSE before work begins. A project is notifiable if it will:

• Last longer than 30 working days with more than 20 workers working simultaneously at any point, or
• Exceed 500 person-days of construction work

If your project is notifiable, you must submit an F10 notification to the HSE as early as practicable before work starts. The Site Book checks this automatically from your project data and pre-fills the F10 form for you.

The Construction Phase Plan

The CPP is the main CDM document produced by the principal contractor. It sets out how health and safety will be managed on site throughout the construction phase. It must be in place before construction starts and must be kept up to date as the project progresses.

A CPP must cover:

• Project description and scope of works
• Management arrangements, including who is responsible for what
• Site rules and welfare arrangements
• Emergency procedures, including nearest A&E and evacuation routes
• Arrangements for controlling significant site risks
• The health and safety file arrangements

The CPP does not need to be hundreds of pages. It needs to be proportionate to the project. A small domestic extension needs a shorter CPP than a multi-storey commercial build. What matters is that it accurately reflects how safety will be managed on this particular project.

Penalties for non-compliance

CDM 2015 is enforced by the HSE. Breaches can result in:

• Prohibition notices (work stopped immediately until the issue is resolved)
• Improvement notices (must fix within a set period or face prosecution)
• Prosecution and fines (unlimited in serious cases)
• In cases of gross negligence, imprisonment for individuals

The HSE carries out unannounced site visits. They do not need to give notice. The time to have your documentation in order is before they arrive, not after.

What you need in practice

For most construction contractors acting as principal contractor, CDM 2015 requires:

1. 1A Construction Phase Plan before work starts
2. 2A RAMS (Risk Assessment and Method Statement) for significant risk activities
3. 3A site induction for every worker before they start on site
4. 4Welfare facilities on site that meet the minimum requirements
5. 5F10 notification if the project is notifiable
6. 6Records of incidents, near misses, and any RIDDOR-reportable events
7. 7Coordination of subcontractors and their documentation

Getting all of this right is not optional, and the penalties for getting it wrong are real. The Site Book covers all of it in one place, so nothing falls through the cracks.